According to the lawsuit the infighting began in August 2016 when the NBCE Board met and voted on whether Norman Ouzts DC, a then current NBCE Board member, should be hired as the next Executive Director of the NBCE.

The suit states that Ouzts was a long time friend and/or close colleague or confidant to some of the male members of the Board including Farrel Grossman DC.

At that time the Board did not vote in favor of hiring Ouzts because he was not qualified according to the suit.

The lawsuit further alleges that certain members of the Board modified the job description and in October 2016 Ouzts was again presented to the Board for consideration. The vote passed despite four of the Directors voting against Ouzts' hiring.

But that did not end the controversy.

According to the lawsuit, in April 2017, an anonymous sender mailed a two-page pamphlet titled National Board of Corrupt Examiners: Strikes Again. The lawsuit refers to the letter as the "Corruption Letter".

The Defendants in the suit were angered by the "Corruption Letter" and hired an attorney to investigate the letter.

Believing the "Corruption Letter" was an "inside job" the Defendants couched the investigation as an "Ethics Investigation" and that any failure on the part of Colucci to participate would, in and of itself, be considered an "Ethics Violation".

What followed was a series of interviews of all Board members by investigators including Colucci who was interviewed for two hours in what her attorney describes as "an interrogation."

In July 2017 Colucci received a letter from the NBCE attorney indicating she was one of three people involved with the creation and/or dissemination of the "Corruption Letter" and that he wanted to depose her.

The suit alleges that Grossman told others that Colucci was in "big trouble" and that her tenure as FCLB President would ". . . be the shortest tenure of Board Presidency ever."

The suit alleges that Steve Conway DC stated the purpose of the deposition was to catch Colucci perjuring herself.

That, and because the conclusions being reached were done outside of properly noticed meetings, Colucci did not want to subject herself to a deposition. She felt the whole thing was a "set up".

Then in October 2017 the Defendants called a surprise vote to remove Colucci from the Board for ". . . failing to cooperate with the ethics investigation . . ."

The Defendants were not successful and Colucci was not removed from the Board at that time.

The lawsuit alleges that select and incomplete information, errors and inaccuracies were used in an effort to have her removed. On January 23, 2018 Colucci's attorney told the NBCE that she would not sit for a pre-action deposition and then on January 30, 2018 Colucci voluntarily took a polygraph exam related to the "Corruption Letter" and according to the polygraph examiner Colucci's answers that she was not involved with it were "truthful".

The results of the polygraph were sent to the NBCE attorney.

Then in a series of events leading up to a February 23, 2018 Board meeting in Phoenix, Colucci was told by Director Shilts that "these guys hate your guts" that "they are going to do everything they can to get rid of you" and that Dr. Grossman had a "vendetta" against Colucci. They even went so far as drafting a resignation letter for her.

On February 23, 2018 the lawsuit contends that the NBCE Defendants held an unplanned executive session and voted 9-2 to remove Colucci from the Board because she had emailed her attorney's letters to the entire Board. Colucci did so, the suit maintains, because not all Board members were given the letters. Just prior to the vote, the suit maintains, Director LaRusso stated: "If at anytime anyone on this Board doesn't like or trust anyone they can be removed at any time."

The lawsuit seeks a jury trial.

According to publicly available tax records, in 2016 the NBCE had $29,748,379.00 in assets and in 2016 alone had total revenue of $11,142,547.00.

NBCE paid out $3,773,067.00 in salaries in 2016.

The Board of Directors paid themselves a total of $231,450.00 in 2016 alone for one hour of work per week.

Norman Ouzts was paid $31,400.00 in 2016 as just a member of the Board of Directors for one hour of work per week. This comes out to $603.00 per week.

Ouzts total NBCE compensation from 2008-2016 was just over $225,000.00 as a member of the Board of Directors.

According to the 2016 NBCE tax records the EVP position Ouzts took over had a total annual compensation of $199,794.00.

The approximately $11,000.000.00 in NBCE revenue each year comes from testing students on mandated examinations they need in order to get licensed in the majority of jurisdictions. The vast majority of students get their money from student loans.